Instituting a quality management involvement program - Part I
This is the first in a two-part series of articles. Part I explores the financial reasons companies should move toward making proper hazardous waste handling and reduction part of their corporate culture. Part II, which will appear in an upcoming issue, examines ways to institute a program for achieving this goal.
Virtually all plant managers and environmental consultants understand the need to handle hazardous waste correctly; proper handling is a matter of law. Not everyone, however, understands the benefits of proper handling on the overall profitability of a company, or what happens to that profitability when waste is improperly handled. More importantly, when a company attempts to transform itself into an institution that models, seeks and trains employees in environmental "good citizenship" across the entire enterprise, will that help or hinder profits?
All of the ways in which facilities handle waste fall under the "must comply" rather than the "want to comply" motivational set. That is, individuals follow the rules because they have to. Experience suggests, however, that there is a real need to entirely rethink such routine hazardous waste handling training. Changing to a "want to comply" attitude can dramatically transform an organization to an extent impossible through compliance that's simply performed because it is required. By significantly altering the company's vision to one that holds true environmental caring as a key management point, the company can become more profitable.
Profit through quality
In the 1980s, many manufacturers realized the quality of their performance would not improve unless it can be measured in quantitative terms. Thus, when the total costs of scrap, rework, downtime and other "non-measurable" factors actually began to be calculated, assuring quality in manufacturing turned out to be the most profitable way to run a business. As the concept of "zero defects" was created, manufacturers quietly and quickly realized that attaining that goal would, in the end, make them vastly more profitable than any other single measure they could implement.
In many respects, handling hazardous waste is no different from handling a manufacturing process. Waste will be generated as long as processes take place. The concept of "zero incidents" or "zero violations" can also make a company more profitable.
Until recently, many manufacturers have not focused on all the costs related to non-compliance. Everyone knows non-compliance costs money and places costs on the environment. But does anyone truly know the value properly handling a waste brings to a business? As businesses begin to measure such costs, they generally find there is a real penalty associated with handling waste improperly that affects their bottom line.
For example, shortly after implementing a hazardous waste program, one manufacturer reduced the amount of water used in one of its processes by 53 percent. The company realized estimated annual savings between $25,000 to $35,000 and received awards for its conservation efforts. Another company, a large quantity generator of solvents, installed measures that reduced the amount of waste to below the small-quantity-generator (SQG) threshold of 100 kilograms per month. Payback for the company was over several years, based on disposal cost savings of about $2,000 per year and raw materials savings of $3,000 per year.
There are other examples throughout the country of such effects when a "want to comply" attitude is followed. The difficulty is that, unlike the quality movement which sprang from within (i.e., manufacturers realizing and embracing quality), the impetus for properly handling hazardous wastes is driven largely from the outside that is, government rules and regulations. And therein lies the problem: doing something because you "want to" is vastly different than doing something because you "have to." The key is to move toward a "want to" culture.
How much paperwork does a company generate in striving to comply with the government rules and regulations? How much time and labor is needed to move that paper? What are the costs to the business's bottom line? For example, if a company maintains material safety data sheets, it could be more economical to use the allowable fax-on-demand service. A cost analysis will indicate the pros and cons of instituting such measures.
The Resource Conservation and Recovery Act (RCRA) was enacted to protect human health and the environment as well as to conserve valuable materials and energy resources. The most important aspect of RCRA is the establishment of standards for the management and tracking of waste from generator to transporter to treatment, storage and disposal. One of the results of instituting this law has been paperwork to document these activities a lot of paperwork.
The government has enacted laws to try to limit the implications of RCRA paperwork. According to the Federal Register, No. 117, June 18, 1999, to meet the goals of the Paperwork Reduction Act of 1995, the Office of Solid Waste (OSW) is striving to reduce the record keeping and reporting burden on states, the public and regulated community associated with RCRA. On Sept. 30, 1995, the paperwork burden baseline for the OSW's regulations was 12,600,000 hours. As of Oct. 1, 1998, the office achieved burden reductions totaling nearly 2,000,000 hours, or 16 percent. To date, no one has been able to estimate the amount of paper associated with these millions of hours.
Some of the ideas for reducing paperwork are controversial and may not necessarily be implemented in rulemaking. One such idea involved examining whether the U.S. Environmental Protection Agency (EPA) should allow facilities to submit and store information electronically. On Nov. 2, 1996, EPA wrote an interpretive letter to Safety-Kleen Corp. saying the company could store electronic image files of manifests instead of keeping paper copies. In addition, a pilot project was initiated to test the feasibility of using electronic data interchange and the Internet to automate manifesting activities. In this pilot, users prepared, transmitted and kept copies of a digitally signed electronic manifest. The pilot was completed in September 1999 and is now being evaluated by EPA as part of a proposed manifest revision rule.
EPA has been working to introduce electronic reporting and record keeping into its programs to eliminate cost to industry and government and to eliminate the errors and delays involved in keystroking reports into databases. The long-term goal is to use electronic reporting as a tool for streamlining and automating the exchanges of data among industry, environmental agencies and the public.
Even the government is at a stage where "want to" is emerging as the driving motivation for helping businesses meet compliance regulations. There is a huge incentive for industry to reduce the amount of waste it produces. Disposal is becoming increasingly expensive. When companies produce less waste, their disposal costs are lower. Companies may also profit from selling or saving recovered materials. The process changes that will result in these savings must begin with individuals who understand the implications of handling hazardous wastes properly. In other words, from people who "want to" people who care.
How caring relates to profits
Caring from within requires important changes in the mindsets of management. Changes that will help achieve these important and ambitious goals of waste management require the cooperation of all departments, including the way research into hazardous waste handling is conducted, management of hazardous waste teaching and the design of projects that involve hazardous waste management. One way is addressing and effecting attitudes through Quality Management Involvement (QMI) programs, which are company-initiated programs designed to improve specific processes such as hazardous waste management.
QMI programs entail management's involvement for a long period of time. The quality movement is such a movement. There is now a real need for a QMI program associated with the handling of hazardous and non-hazardous wastes.
For example, the New York Department of Environmental Control's (DEC) multimedia pollution prevention program focuses on the 400 facilities responsible for 95 percent of New York's waste. Under this program, teams from the DEC's nine regions are formed to conduct multimedia inspections at about 10 percent of each region's facilities per year. The New York DEC uses hazardous waste generation data, applicability of the state's pollution prevention facility planning requirements, location of sensitive receptors, public concern, ongoing enforcement, compliance records and other factors to determine which facilities to inspect first.
At 10 percent per year, it takes 10 years to cover all 400 facilities. Under a QMI program, these 400 facilities would not only welcome these outside efforts, they would be practicing zero violations on an ongoing basis. Under QMI, each of the facilities would do what the DEC does, but within its own facility. Each facility would cross-train its employees to be "inspectors" in regulatory and pollution prevention planning requirements. QMI encourages the use of pollution prevention solutions identified in the facility hazardous waste reduction plans to solve compliance problems.
Consider another example. RCRA regulations require large quantity generators and treatment, storage and disposal facilities to inspect their facilities to ensure that they are operating in compliance with RCRA requirements. The regulations include both facility-wide and specific types of unit and equipment inspection standards. Some of RCRA's inspection requirements specify inspection frequencies. An owner of a container storage area must inspect it at least weekly, while an owner of a tank must inspect it daily. RCRA's inspection requirements can be found throughout the regulations, but mostly in 40 Code of Federal Regualtions Parts 264 and 265.
In the QMI programs being proposed, these would be the starting points of inspections. In fact, inspections regardless of whether a large or small quantity generator would be an ongoing process performed by everyone on the factory floor. This working from within the culture leads to analysis and diagnostics far ahead of problems. Indeed, if one is inspecting constantly from within, then it hardly matters when the outside inspector shows up.
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This article appeared in Environmental Protection magazine, May 2000, Vol. 11, No. 5, p. 42. Photo courtesy of Safety-Kleen Corp.
This article originally appeared in the 05/01/2000 issue of Environmental Protection.
Sandra Bienkowski is the editor of Home Health Products. She can be contacted at (972) 687-6786.